2026 CBP Form 5106 Update: New IOR Customs Requirements Starting September 18

U.S. Customs and Border Protection (CBP) is increasing enforcement of Importer of Record (IOR) information. Starting September 18, 2026, CBP may immediately void an IOR number if the information on CBP Form 5106 is inaccurate or incomplete. A voided IOR number cannot be used to enter merchandise into the United States.

CBP Form 5106: What Changes on September 18?

Under the new enforcement, CBP will verify information provided by new and existing importers. The information on CBP Form 5106 must be accurate, complete, and directly associated with the Importer of Record.

This includes:

• Legal business name

• EIN or other required tax identification

• Physical business address

• Phone number

• Email address

  
  

Most importantly, the physical address cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center, or another company's address. The phone number and email must also belong directly to the IOR.

IOR Customs: What Importers Should Review

Before September 18, businesses should review their IOR customs information and make sure their records are current.

Importers should:

• Verify their CBP Form 5106

• Confirm their physical business address

• Check their EIN and legal business name

• Verify their phone and email

• Review their Customs Power of Attorney (POA)

  
  

Customs brokers submitting Form 5106 on behalf of an importer must also have a valid POA executed directly with the IOR.

Importer of Record Compliance Matters

The Importer of Record remains responsible for the accuracy of its import information, even when a customs broker handles the entry.

If CBP determines that the information is inaccurate or incomplete after September 18, the associated IOR number may be voided immediately, preventing it from being used for U.S. import entries. CBP will provide notice and instructions for requesting reestablishment of a voided IOR number.

FBD GROUPS: Supporting U.S. Import Logistics

Compliance is only one part of the import process. Businesses also need reliable freight, customs clearance, drayage, warehousing, and fulfillment.

FBD GROUPS provides integrated 3PL solutions across these areas, with specialized experience in electronics, batteries, e-mobility, renewable energy, and Class 8 & 9 dangerous goods.

As businesses expand into the U.S., FBD GROUPS helps connect international transportation with U.S. logistics and fulfillment for a more streamlined supply chain.

Learn more about FBD GROUPS

Review Your CBP Form 5106 Before September 18

With the new September 18, 2026 enforcement date approaching, importers should review their CBP Form 5106, IOR customs information, and Importer of Record details now.